16 September 2019
Hon Kevin Andrews MP
Chair
Joint Standing Committee on the National Disability Insurance Scheme
Dear Mr Andrews
The Australian National Audit Office (ANAO) published the following performance audit reports that you may find relevant to the Joint Standing Committee on the National Disability Insurance Scheme’s inquiry into supporting NDIS planning.
- Report No. 13 of 2017-2018 Decision-making Controls for Sustainability — National Disability
Insurance Scheme Access
• Report No. 24 of 2016-2017 National Disability Insurance Scheme - Management of
Transition of the Disability Services Market
Information about what the audit assessed, concluded and recommended is attached. The audit report is available online at www.anao.gov.au.
Should the Committee require further information in relation to this matter, my office would be pleased to provide you with a briefing at a time convenient to you or appear as a witness at a hearing.
To arrange a briefing, please contact our External Relations area at
Yours sincerely
Grant Hehir
Report No. 13 of 2017-2018 Decision-making Controls for Sustainability — National Disability Insurance Scheme Access assessed the effectiveness of controls being implemented and/or developed by the National Disability Insurance Agency (NDIA) to ensure National Disability Insurance Scheme (NDIS) access decisions are consistent with legislative and other requirements. To form a conclusion against the audit objective, the following high-level audit criteria were adopted:
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Suitable information, training and guidance is available to support effective decision-making about access to the NDIS.
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Suitable administrative systems and processes are in place to support transparent, accurate, timely and consistent assessment of NDIS eligibility.
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Suitable quality and compliance arrangements have been established to mitigate the risk of incorrect NDIS access decisions.
The audit concluded:
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The NDIA has implemented some controls to ensure that NDIS access decisions are consistent with legislative requirements, but these have been inconsistently applied. As at August 2017, the NDIA is developing an integrated assurance framework to enhance decision-making controls.
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Accurate and accessible information is available for consumers and carers about how to access the NDIS. Suitable training and guidance is available to support access decision making by NDIA officers and processing of access requests by Human Services’ staff.
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Data integrity and reporting issues limit the NDIA’s ability to monitor training completion by access decision-makers. In addition, NDIA requirements for on-the-job training were not
documented and the ANAO found limited evidence that these requirements were
implemented.
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The NDIA’s access processes supported the transition of a large volume of people into the NDIS in a short space of time. In practice, the ANAO observed legislative and administrative non-compliance that potentially affected the transparency, accuracy and timeliness of access decisions.
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The access process was not well supported by the first stage of the NDIA’s ICT system, introduced in July 2016, requiring implementation of inefficient manual work-arounds. The NDIA advised the ANAO that new ICT workflow management functionality was implemented from July 2017.
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The NDIA had not established efficient or effective processes for internally reviewing access decisions. New procedures introduced by the NDIA in May 2017, if implemented effectively, will provide an internal review process that is consistent with legislative requirements.
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The NDIA has implemented executive monitoring and reporting of strategic and operational risks, including risks to Scheme financial sustainability, which is informed by actuarial analysis of Scheme outlays and risks.
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Comprehensive quality and compliance arrangements have not been implemented to mitigate the risk of incorrect NDIS access decisions. These are currently in development as part of a broader integrated assurance framework.
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The ANAO recommended:
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The National Disability Insurance Agency should establish, implement and monitor a robust quality framework for access decisions addressing training, ongoing assessment of officer proficiency and decision quality.
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The National Disability Insurance Agency should ensure that the business rules underpinning computer aided decision-making are clearly documented, aligned with legislative and policy requirements, and verified to ensure they have been correctly incorporated into the National Disability Insurance Agency ICT system.
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The National Disability Insurance Agency should review its processes to include reassessments of the eligibility of participants who enter the Scheme under the disability requirements, taking into account levels of impairment, and conditions that have greater prospects of improvement.
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The National Disability Insurance Agency should implement quality control and assurance processes for internal reviews of access decisions, with the aim of supporting accurate, consistent and transparent decision-making.
Report No. 24 of 2016-2017 National Disability Insurance Scheme - Management of Transition of the Disability Services Market assessed the effectiveness to date of the management of the approach to transition the disability services market to the National Disability Insurance Scheme (NDIS) market arrangements. To form a conclusion against the audit objective, the following high level audit criteria were adopted:
- the approach by the department and the NDIA to transition the disability services market has been informed by lessons learnt from the trial sites and other relevant market
transformations;
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the department and the NDIA have effectively considered implementation issues in their management of the approach to transitioning the disability services market;
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the Sector Development Fund has been used strategically to support and inform the transition of the disability services market; and
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the department and the NDIA have effective mechanisms to continue to adjust and refine their approach to transitioning the disability services market.
The audit concluded:
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By mid-2016 the department and the NDIA had established, or had taken steps to establish, the key building blocks for a successful transition of the disability services market to the new NDIS arrangements, but many risks and some gaps remain.
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Within NDIS’ intergovernmental governance arrangements, the processes and timeframes for collective decision-making have been inconsistent with the timeframes for the rollout of the Scheme. This, along with a lack of clarity over roles and responsibilities, has contributed to delays, risk and complexity.
• There is limited evidence of a strategic approach to the use of the Commonwealth’s
$146 million Sector Development Fund, in the first three years of the Fund’s administration.
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Both the department and the NDIA have captured, analysed and used lessons from the trial sites to develop market policy and operational settings in response to feedback and experience.
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While the department did not have a clearly documented work program to implement its disability workforce development responsibilities, the Agency documented a program of activities to operationalise its market transition responsibilities. However there was no published overall work plan which sets out timeframes and deliverables.
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There is a high degree of executive oversight of NDIS risks within both DSS and the NDIA but opportunities remain to enhance both intergovernmental and Commonwealth risk
management.
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Both the department and the NDIA have recently changed their organisational arrangements to improve their ability to meet their responsibilities. In October 2016, DSS developed a draft NDIS Transition Program Plan to support its market oversight role in the NDIS market transition. The NDIA’s transition planning provides for continued collection of data, and mechanisms are in place, or under development, to improve data collection.
• Finalising the national NDIS Quality and Safeguarding Framework and its supporting
infrastructure and implementation arrangements needs to be a priority to improve regulatory certainty and address market transition risks. The deployment of a new NDIS ICT system from July 2016 experienced significant problems. Timely and accurate communication is essential in such circumstances.
- Going forward, the NDIS is a complex social and economic reform. The magnitude of the growth and change required to the disability services market cannot be underestimated, and the transition to full Scheme elevates an already high risk environment. This requires ongoing monitoring and active management. Within this context, both DSS and the NDIA need to invest in their capability to identify and resolve emerging market concerns for many years to come.
The ANAO recommended:
- The Department of Social Services should produce and publish a disability care workforce action plan as soon as practicable, which includes specific actions, timeframes,
accountabilities, and monitoring arrangements for implementation.
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